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Animal model or human cells: efficacy evidence for approved vaccines

From the FDA and EMA reviews of all 13 approved vaccines. Each answer links to the regulator's own sentence.

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Short answer
11 of 13 approved vaccines never tested the clinical molecule in an animal disease model; 0 rested on human cells or in vitro data alone.
In vivo disease model2/13
In vivo pharmacology, no disease model11/13

Precedent by precedent

13 approved vaccines, with the reviewers' own words.

Cyfendus

anthrax vaccine adsorbed, adjuvanted · B. anthracis PA; TLR9 (CpG 7909 adjuvant)
Efficacy evidence
Guinea pig and cynomolgus macaque lethal aerosolized B. anthracis spore challenge after two IM vaccinations
“Efficacy studies for CYFENDUS were conducted in guinea pigs and cynomolgus macaques. Animals received two intramuscular vaccinations two weeks apart with various dilutions of CYFENDUS and were challenged with a lethal dose of aerosolized B. anthracis spores on Day 28 or 70.”
✓ VerifiedUS package insert, p. 10Source ↗
Why that model
CpG 7909 activity significantly weaker in rabbits, so a guinea pig inhalational anthrax model was developed
“The activity of the CpG 7909 adjuvant has been observed to be significantly weaker in rabbits; therefore, to provide a suitable additional animal to demonstrate the effectiveness of CYFENDUS, the applicant developed and used a guinea pig model of inhalational anthrax.”
✓ VerifiedFDA summary basis for approval, p. 17Source ↗

Nuvaxovid

COVID-19 vaccine, recombinant spike protein nanoparticle, Matrix-M-adjuvanted · SARS-CoV-2 spike (nanoparticle)
Efficacy evidence
SARS-CoV-2 live-virus challenge in mice, hamsters, cynomolgus and rhesus macaques
“Live virus challenge studies were performed in mice, hamsters, cynomolgus macaques, and rhesus macaques.”
✓ VerifiedEMA assessment report, p. 47Source ↗
Why that model
Mice made susceptible by intranasal adenovirus vector expressing human ACE2 before challenge
“The 2 lead antigens were tested for protective effect against SARS-CoV-2 challenge, at 10 μg level, with or without 5 ug Matrix-M1 adjuvant, in a prime-boost regime in mice sensitised for SARS-CoV-2 by intranasal instillation of adenovirus vector expressing human ACE2.”
✓ VerifiedEMA assessment report, p. 48Source ↗

Arexvy

respiratory syncytial virus vaccine, adjuvanted (AS01E) · RSV preF3; TLR4 (AS01E adjuvant)
Efficacy evidence
Immunogenicity of RSVPreF3 with or without AS01 in naive mice (neutralising antibodies, CD4+/CD8+ T cells); no challenge model
“The Applicant has submitted three primary PD studies to characterise the immunogenicity of the PreF3-AS01E vaccine in mice and two immuno-characterization studies.”
✓ VerifiedEMA assessment report, p. 29Source ↗
Why that model
No animal model mimics the non-naive elderly population and its sensitivity to RSV disease
“The Applicant has thoroughly explained that the non-clinical studies are only intended to show immunogenicity and not to evaluate vaccine efficacy, because a good animal model that can mimic the intended human non-naïve elderly target population and the sensitivity to RSV-related disease upon infection is not present.”
✓ VerifiedEMA assessment report, p. 29Source ↗

Cervarix

human papillomavirus bivalent (types 16, 18) vaccine, recombinant, AS04-adjuvanted · HPV 16/18 L1 VLPs; TLR4 (AS04 adjuvant)
Efficacy evidence
Immunogenicity in mice and rhesus monkeys (AS04 superior to aluminium alone); no protection model
“Primary pharmacodynamic studies in mice and monkeys show that the activation of the innate immunity by AS04 is paralleled by the induction of a strong and persistent specific immune response by the Cervarix vaccine.”
✓ VerifiedEMA assessment report, p. 53Source ↗
Why that model
HPV species specificity precludes animal protection models
“Given the species specificity of HPV precluding the evaluation of any human HPV-16/18 vaccine in protection animal models, primary pharmacodynamic studies aimed at the preclinical evaluation of the immunogenicity of the HPV-16/18 L1 VLP AS04 vaccine were carried out in mice and Rhesus monkeys.”
✓ VerifiedEMA assessment report, p. 9Source ↗

Fendrix

hepatitis B vaccine (rDNA), AS04C-adjuvanted · HBsAg VLPs; TLR4 (AS04C adjuvant)
Efficacy evidence
Immunogenicity in mice: HBsAg with AS04C more immunogenic than with alum
“A better immunogenicity was obtained in mice when HBsAg was formulated with AS04C than with alum, as in a commercially available HepB vaccine.”
✓ VerifiedEMA assessment report, p. 24Source ↗
Why that model
Not stated in public reviews

Flublok

influenza vaccine, recombinant hemagglutinin · Influenza HA
Efficacy evidence
Mouse immunogenicity (HAI and neutralizing antibodies) with monovalent rH3 and trivalent RIV3; no challenge studies
“The results from these studies show that RIV3 and rH3 are immunogenic and can induce serum HAI and nAb antibodies against the influenza strains present in the vaccine.”
✓ VerifiedEMA assessment report, p. 26Source ↗
Why that model
Extensive human pharmacodynamic data with RIV3 and RIV4; no animal immunogenicity or challenge studies with RIV4
“No specific non-clinical pharmacology studies including immunogenicity and challenge-protection studies in animal models have been performed with RIV4. There is large amount of pharmacodynamics data available in humans with both RIV3 and RIV4, both licensed in the US and manufactured using the same manufacturing process as that intended for EU.”
✓ VerifiedEMA assessment report, p. 25Source ↗

Gardasil

human papillomavirus quadrivalent (types 6, 11, 16, 18) vaccine, recombinant · HPV 6/11/16/18 L1 VLPs
Efficacy evidence
Immunogenicity in rhesus macaques, chimpanzees and African green monkeys; neutralising antibodies; no HPV challenge model
“In each of the 3 non-human primate species tested, the intramuscular administration of Gardasil, or it’s monovalent components, was found to elicit immune responses resulting in production of antibodies against the HPV VLP types present in the vaccine.”
✓ VerifiedEMA assessment report, p. 7Source ↗
Why that model
No animal model of human papillomavirus infection; species-specific papillomaviruses used instead
“There is no animal model for human papillomavirus infection, however there are other species-specific papillomaviruses that have been studied in animal models.”
✓ VerifiedEMA assessment report, p. 7Source ↗

Gardasil 9

human papillomavirus 9-valent vaccine, recombinant · HPV 9-valent L1 VLPs
Efficacy evidence
Immunogenicity in rhesus macaques (non-GLP): antibodies to all 9 HPV types; no protection model
“The vaccine elicited a robust immune response in all the animals resulting in the production of antibodies against each of the nine HPV types (6, 11, 16, 18, 31, 33, 45, 52 and 58) present in the vaccine.”
✓ VerifiedEMA assessment report, p. 23Source ↗
Why that model
No animal model of human papillomavirus infection, so protection could not be tested
“There is no animal model for human papilloma virus infection. Therefore, the vaccine could not be tested for protection in animals.”
✓ VerifiedEMA assessment report, p. 23Source ↗

HBVaxPro

hepatitis B vaccine (rDNA) · HBsAg VLPs
Efficacy evidence
C3H mouse potency (ED50) testing versus the licensed thiomersal-containing vaccine
“In-vivo potency testing in C3H mice showed the thiomersal-free vaccine to be highly potent and comparable to that of the thiomersal-containing formulation.”
✓ VerifiedEMA assessment report, p. 4Source ↗
Why that model
Not stated in public reviews

Heplisav-B

hepatitis B vaccine (recombinant), adjuvanted · HBsAg; TLR9 (CpG 1018 adjuvant)
Efficacy evidence
Anti-HBsAg immunogenicity of the adjuvanted vaccine in mice, rats and baboons
“The immunogenicity of HBsAg adjuvanted with 1018 ISS has been evaluated in mice, rat and baboons.”
✓ VerifiedEMA assessment report, p. 21Source ↗
Why that model
Animal anti-HBV responses read against the human seroprotection threshold (>=10 mIU/ml); response depended on CpG adjuvant dose
“The immunogenicity studies also demonstrated that the anti-HBV antibody response and more importantly the frequency of animals responding with antibody levels ≥10 mIU/ml (the defined threshold for seroprotection in humans) is depending on the 1018 ISS dose.”
✓ VerifiedEMA assessment report, p. 22Source ↗

Mosquirix

RTS,S/AS01 malaria vaccine · P. falciparum CSP-HBsAg (RTS,S) VLPs; TLR4 (AS01 adjuvant)
Efficacy evidence
Immunogenicity in mice and monkeys (3 IM doses, days 0, 14, 28)
“The vaccine schedule was 3 intramuscular (i.m.) injections on days 0, 14 and 28, except GSK041 study in monkeys and two mouse studies (LIMS 20110165, LIMS 20130320) designed with immunobridging objectives.”
✓ VerifiedEMA assessment report, p. 34Source ↗
Why that model
Not stated in public reviews

PreHevbrio

hepatitis B vaccine (recombinant), 3-antigen · HBsAg S/pre-S1/pre-S2 VLPs
Efficacy evidence
Immunogenicity in mice and rats; no challenge model
“The pharmacology studies clearly establish the immunogenicity of PreHevbri in immunized mice and rats.”
✓ VerifiedEMA assessment report, p. 26Source ↗
Why that model
Rodents used because they respond to HBsAg
“The suitability of rodent species for these studies was supported by their responsiveness to HBsAg.”
✓ VerifiedEMA assessment report, p. 23Source ↗

Shingrix

zoster vaccine recombinant, AS01B-adjuvanted · VZV glycoprotein E; TLR4 (AS01B adjuvant)
Efficacy evidence
Immunogenicity (cellular and humoral anti-gE) in mice
“Primary pharmacodynamics studied in mice to evaluate cellular and humoral anti-gE antigen immune responses and to select the optimal formulations”
✓ VerifiedEMA assessment report, p. 27Source ↗
Why that model
No appropriate animal model of VZV pathogenesis, latency or reactivation, so no challenge studies
“There is no appropriate animal model to study Varicella Zoster Virus (VZV) pathogenesis, latency or reactivation. Hence, no non-clinical data on protection against Herpes Zoster by vaccine candidates (challenge studies) were generated.”
✓ VerifiedEMA assessment report, p. 27Source ↗